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    <title>2019 (1) TMI 270 - ITAT KOLKATA</title>
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    <description>Under the project completion method, estimated provision for unfinished ancillary work was treated as deductible where the project was substantially completed, revenue had been recognised, and the liability had accrued but could be reasonably estimated; the corresponding disallowance was therefore unsustainable. Disallowance under the tax deduction at source provisions also failed for raw material purchases, which were outside the usual TDS ambit, and for expenditure where tax had already been deducted and deposited within the permitted time. On those facts, the disputed additions were deleted and the assessee&#039;s case prevailed.</description>
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      <description>Under the project completion method, estimated provision for unfinished ancillary work was treated as deductible where the project was substantially completed, revenue had been recognised, and the liability had accrued but could be reasonably estimated; the corresponding disallowance was therefore unsustainable. Disallowance under the tax deduction at source provisions also failed for raw material purchases, which were outside the usual TDS ambit, and for expenditure where tax had already been deducted and deposited within the permitted time. On those facts, the disputed additions were deleted and the assessee&#039;s case prevailed.</description>
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